Quick Answer
For an EU cosmetic product, Article 19 of Regulation (EC) No 1223/2009 sets the core label information: Responsible Person details, nominal content, durability or period after opening, precautions, batch reference, product function when unclear, and an ingredients list. Some placement and language rules vary by item and Member State. The Responsible Person should approve the final container and outer-pack artwork against the marketed formula and current law.
This guide is an artwork-review framework for international beauty brands, not a substitute for a product-specific legal review. Start with the current EU Cosmetics Regulation, especially Article 19 and Annex VII; check later amendments and the destination Member State before printing.
What must appear on an EU cosmetic label?
Article 19 requires indelible, easily legible and visible information on the container and packaging, subject to the specific exceptions in that article. It does not mean every item can be moved freely to a website or QR code. Treat the actual sale unit—bottle, jar, sachet and any outer carton—as the artwork under review.
| Label item | What to verify | Typical evidence owner |
|---|---|---|
| Responsible Person name and address | Identify the EU Responsible Person; highlight the address where the PIF is readily available if several addresses appear. State the country of origin for imported cosmetics. | Brand / EU Responsible Person |
| Nominal content | Show weight or volume at packaging, unless a statutory exception applies, such as certain small packs, free samples or single-use packs. | Brand / pack supplier |
| Durability or PAO | Use a minimum-durability date when applicable; for products durable more than 30 months, show the period after opening unless the concept is irrelevant. | Safety assessor / brand |
| Particular precautions | Include applicable precautions, including those required by relevant Annex entries and professional-use information. | Safety assessor / Responsible Person |
| Batch reference | Provide a manufacture batch number or reference identifying the product. | Manufacturer / brand |
| Product function | State the function unless it is clear from presentation. | Brand / Responsible Person |
| Ingredients | Use the prescribed Ingredients list and naming/order rules, including applicable fragrance-allergen declarations. | Formula owner / brand |
The detailed legal placement exceptions are important. For example, where a product is too small to carry particular precautions or the ingredient list, Article 19 provides specified leaflet, label, tape, tag or card mechanisms and symbols; these are not a blanket permission to omit the information. A tiny pack needs a documented packaging solution.
Container versus outer carton: a two-surface check
Review both surfaces. The Article 19 opening rule refers to container and packaging, but paragraphs 2 and 3 provide item-specific exceptions. A design that looks complete on a carton may fail once consumers discard it, while a crowded jar label may need a lawful attached-information solution. Check legibility on the actual printed dimensions rather than judging a zoomed PDF.
| Review stage | Container or immediate pack | Outer pack and market handoff |
|---|---|---|
| Legal baseline | Confirm required identity, durability, precautions, batch and function placement for this format. | Confirm all applicable Article 19 information and the ingredients list. |
| Translation | Check any consumer-facing text that must be understood locally. | Validate each destination Member State language requirement. |
| Production proof | Inspect real-size type, contrast, adhesion and batch-code location. | Compare proof with approved formula, claims and PIF identifiers. |
| Release control | Keep signed artwork version and batch-coding instructions. | Do not ship a market variant until the Responsible Person approves its final artwork. |
How should the ingredients list be written?
Article 19(1)(g) calls for the list to be preceded by the word “Ingredients”. Ingredients are listed in descending order of weight at the time they are added, except those at less than 1% may appear in any order after ingredients above 1%. Colourants may appear after other ingredients in any order, subject to the specific rules for decorative-cosmetic shade ranges. Ingredient names follow the EU glossary approach; trade names alone are not enough.
Perfume and aromatic compositions are usually identified as “parfum” or “aroma”, but certain fragrance allergens must additionally be named when their legal thresholds and Annex conditions are met. The European Commission explains the fragrance-allergen labelling rules. Our separate allergen article will address the changing list and transition dates; this general checklist should not be mistaken for a final allergen calculation.
Expiry date, open-jar symbol and batch code
The minimum-durability date rule applies to products with durability of 30 months or less. The relevant Annex VII symbol or the words “best used before the end of” precede the date or its location. For durability longer than 30 months, Article 19 generally requires a period-after-opening indication, except where durability after opening is not relevant. The open-jar symbol and time period must correspond to the stability and safety assessment—not to a marketing preference.
A batch code connects a sold unit to production and quality records. For practical traceability, specify whether it is inkjet printed, laser marked or embossed; keep the location consistent with the approved proof and make it readable after normal handling. A barcode or SKU is not automatically a batch identifier.
Who is responsible for the final label?
The EU Responsible Person is responsible for regulatory compliance of the product placed on the market. A manufacturer can provide accurate formula, INCI, batch and technical data; the brand can supply claims, product positioning and artwork; a safety assessor supplies warnings arising from the assessment. The final market-facing label should be reconciled by the Responsible Person across all these inputs. See the EU Responsible Person guide and the PIF overview for related duties.
When a formula, fragrance, colourant, pack size, target market, responsible entity or claim changes, do not simply reuse the old artwork. Recheck the safety assessment, ingredients list, mandatory warnings, languages and notification before production release.
A practical pre-print artwork checklist
- Lock the exact final formula, product variant, pack format and market list.
- Check Article 19 item by item against both the container and outer package.
- Confirm Responsible Person address, imported-product origin statement and PIF location.
- Generate the Ingredients list from the final formulation, not a pilot batch or old supplier sheet.
- Ask the assessor to confirm durability, PAO, warnings and any ingredient-specific conditions.
- Validate required languages for each destination market and review real-size print proofs.
- Approve the controlled artwork version; preserve the proof, translation sign-off and batch-code specification.
Common mistakes in private-label launches
- Copying a US label into the EU without adding the EU Responsible Person and Article 19 details.
- Listing an ingredient from a supplier marketing name instead of the appropriate common ingredient name.
- Using an open-jar icon on every pack without checking whether PAO applies or what period the evidence supports.
- Assuming CPNP notification corrects a defective physical label.
- Printing several language markets from one artwork without confirming each Member State rule.
- Changing fragrance or claims after the label and CPSR were approved.
These are examples of controls to review, not a statement that every listed mistake occurs on every product.
FAQ
Does the EU require an INCI list on cosmetics?
Article 19 requires an Ingredients list using the applicable common ingredient names and ordering rules. Check the current glossary and product-specific conditions.
Can the ingredients list be on a leaflet?
Only in the circumstances and format permitted by Article 19 when practical packaging constraints apply. A website alone is not a general replacement.
Is the country of origin required?
Article 19(1)(a) requires the country of origin to be specified for imported cosmetic products.
Is the PAO symbol mandatory on every cosmetic?
No. The rule depends on minimum durability and whether durability after opening is relevant; evaluate the specific product.
Who signs off an OEM cosmetic label?
The brand and manufacturer may prepare inputs, but the EU Responsible Person must ensure compliance of the product placed on the EU market.
Sources and review
- EUR-Lex: Regulation (EC) No 1223/2009, especially Article 19 and Annex VII; consult the current consolidated text.
- European Commission: Fragrance allergens labelling.
- European Commission: CosIng; an informational database, not a legal approval.
Last reviewed: 26 September 2026. Editorial responsibility: MOOYAM technical content team, reviewing the official EU materials linked above. This article provides general information, not legal advice. Regulatory requirements may change. Brands should verify current requirements with the relevant authority or a qualified compliance professional before placing cosmetic products on the market.
MOOYAM supports OEM/ODM cosmetic manufacturing and technical documentation for international beauty brands. For a label-ready private-label project, contact us with the final formula, pack size and target EU markets.